February 6, 1997
TO: ACCOUNTING POLICY SUBCOMMITTEE No. 1-97
RE: NOTICE OF MEETING - MARCH 12, 1997; ANNOUNCEMENT OF NEW
COMMITTEE MEMBERS
______________________________________________________________________________
Please join me in welcoming new Accounting Policy Subcommittee ("APS") members Ed
Bedard of NationsBanc Advisors, Bob Bishop of Oppenheimer Management, Bruce Smith of
Van Eck Associates. In addition, I am pleased to announce that Rich Thomas of Federated
Investors has agreed to act as the APS chairman for the next two years. To new committee
members, thank you for your commitment to sit on the Subcommittee and participate in the
drafting of accounting guidance.
Committee Meeting
There will be a meeting of the APS on Wednesday, March 12, 1997. The meeting will
begin at 3:00 p.m. and will continue until approximately 6:00 p.m. The meeting will be held at
the Institute which is located at 1401 H Street, N.W. in Washington. The meeting will take
place in the twelfth floor Operations conference room. APS members whose terms expired in
1996 are also invited to attend the March 12 meeting. The Institute will arrange a dinner for
APS members subsequent to the completion of the committee meeting. Please complete and
return the attached meeting response form (even if you do not plan to attend) by February 28 to
Agnes Thomas either by fax (202/326-5853) or return mail to:
Agnes Thomas
Investment Company Institute
1401 H Street, NW
Washington, DC 20005-2148
Also, there will be a joint meeting of the Accounting/Treasurers Committee and the
Independent Accountants Advisory Group on Thursday, March 13 from 10:00 a.m. to
approximately 2:00 p.m. The Accounting/Treasurers Committee meeting will be held at the
Institute. A separate meeting notice for the Accounting/Treasurers Committee meeting will be
sent to members of that committee.
For your convenience, we have reserved a block of rooms at the Marriott Metro Center
for the night of Wednesday, March 12 at the rate of $150. The Marriott Metro Center is located
at 775 12th Street, N.W. To make a reservation, please call the hotel at 202/737-2200 by
February 20 and ask for a room in the In-House Reservations/Investment Company Institute
block of rooms.
Current Projects
Restricted Securities - The restricted securities disclosure examples paper has been completed
and distributed to the Institutes membership. If you have not yet received a copy of
Accounting/Treasurers Members No. 2-97 (January 9, 1997) please let me know.
Investments in Affiliates - Enclosed you will find an updated version of the investments in
affiliates paper that was presented at the November 20 meeting. Changes to the paper resulting
from comments received at the November 20 meeting are marked. An outstanding issue from
the last meeting was whether the 5% affiliates test should be applied at the complex level or at
the fund level. Similarly, in the case of series company that contains several portfolios, should
the 5% affiliates test be applied at the investment company/registrant level or at the individual
series/portfolio level. After further research we have concluded that affiliates should be
determined at the fund level (not complex level), and at the individual series level (not
investment company level for series companies). Additional language has been added
clarifying the application of the 5% affiliates test. Please review the investments in affiliates
paper and provide any comments you may have to Neal Fuller or the undersigned by February
21. If no substantive comments are received, the paper will be finalized and distributed at that
time.
19 Distribution Notice Survey - A draft memo intended to accompany the chart summarizing
the survey results was distributed at the November 20 meeting. Several APS members have
promised to provide me with their comments on draft memo. I hope to circulate a revised
draft, reflecting all comments received, within the next several weeks so that we can finalize
this project at the March 12 meeting.
Expense Gross-up - Rule 6-07 of Reg S-X - Joe Grainger reviewed a draft version of the
expense gross-up paper at the last meeting. If you have not already done so, please provide
your comments on the paper to Joe so that we can review an updated version of the paper at
the forthcoming meeting.
1997 Meeting Dates
As you know, APS meetings are typically scheduled the afternoon preceding
Accounting/Treasurers Committee meetings. APS meetings will typically be scheduled to run
from 3:00 p.m. to 6:00 p.m. For your information, 1997 meetings of the APS and the
Accounting/Treasurers Committee will be held March 12/13, June 25/26, and November
12/13. An agenda for the March 12 meeting will follow.
Gregory M. Smith
Director - Operations/
Compliance & Fund Accounting
cc: Teresa Westbrook, MLAM
Kathy Hyatt, Vanguard
Charles Hurty, KPMG Peat Marwick
ACCOUNTING POLICY SUBCOMMITTEE
Wednesday, March 12, 1997
Investment Company Institute
1401 H Street, N.W.
Washington, D.C.
Meeting Response Form
NAME: ________________________________________________________
FIRM:
________________________________________________________
Please indicate below whether you will attend the APS meeting on March 12
___________ YES, I will attend the meeting
___________ NO, I will not attend the meeting
Please send this completed form (even if you do not plan to attend) no later than
February 28, 1997 either by fax (202/326-5853) or return mail to:
Agnes Thomas
Investment Company Institute
1401 H Street, NW
Washington, D.C. 20005-2148
NOTE: To make a room reservation, please call the Marriott Metro Center
at 202/737-2200 by February 20 and request a room in the In House
Reservations/Investment Company Institute block of rooms.